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HMRC internal manual

Capital Gains Manual

Value shifting: TCGA92 S30: groups of companies

Disposals before 14 March 1989

Before 14 March 1989 the value shifting rules did not apply to the disposal by one company of shares in another company where the reduction in value resulted from

  • the payment of a dividend at a time when both companies were members of the same group
  • the disposal of an asset by the second company at no gain/no loss under ICTA88/S273 (1) (now TCGA92/S171 (1)) at a time when both companies were members of the same group.

These exclusions were in CGTA79/S26 (7) before amendment by Finance Act 1989.

Disposals from 14 March 1989 to 18 July 2011

FA89 substantially changed the rules applying to intra-group dividends and asset transfers in relation to transactions on or after 14 March 1989, TCGA92/S31 - TCGA92/S34. Detailed instructions on the value shifting rules for groups of companies are at CG46800+.

Disposals from 19 July 2011

Finance Act 2011 introduced the amended TCGA92/S31 as Targeted Anti-Avoidance Rule for disposals of shares and securities by companies on or after 19 July 2011. TCGA92/S30 no longer applies to such disposals. Detailed instructions are at CG48500+.